LKA Group has developed this policy to ensure we identify, support and engage with vulnerable people with consideration, sensitivity, dignity, respect and compassion.

This policy establishes LKA Group’s commitment to supporting vulnerable people affected by family violence in their interactions with LKA Group, by:

  • Identifying and supporting vulnerable people affected by family violence
  • Ensuring that safety is paramount to all our interactions with vulnerable people
  • Implementing processes that minimise the risk of harm to vulnerable people by providing timely, consistent and targeted assistance, and by limiting the number of times vulnerable people need to disclose information about family violence
  • Protecting the privacy and confidentiality of vulnerable people affected by family violence
  • Applying and supporting the Family Violence and Financial Hardship policies of LKA Group’s clients, including referral and notification processes
  • Providing training and support to ensure LKA Group staff are enabled to conduct their roles in accordance with the commitments in this policy
  • Continuously improving our policies, procedures and practices to fulfil these commitments.

The policy should be read in conjunction with LKA Group’s policies on Leave, Code of Conduct, Customer Service, Discrimination & Equal Opportunity, Information Security, Privacy, Sexual Harassment, Records Management and Financial Hardship, and any relevant processes arising from those policies.


Family violence is defined as violent, threatening or other behaviour by a person that coerces or controls a member of the person’s family… or causes the family member to be fearful.[1] It can include but is not limited to emotional abuse, psychological abuse, sexual abuse, financial or economic abuse, and property damage.

Family member or member of the person’s family includes a spouse or former spouse, de facto partner or former de facto partner, child (any child of the person including an adult, foster, adopted or stepchild), parent, grandparent, grandchild or sibling, and persons related to the person according to the customs of Aboriginal or Torres Strait Islander peoples. For the purpose of this policy, family member may also include co-habitants.

Vulnerable person is any person affected by family violence who is interacting with LKA Group as an employee, contractor, customer or other stakeholder.

LKA Group recognises that vulnerability can be increased by other factors such as race, gender, sexual identity, language and disability, and we take an intersectional approach to implementing this Policy for all vulnerable persons which recognises and supports these complexities.

[1] Family Law Act 1975 (Cth) s 4AB.


This policy applies to all LKA Group staff and contractors. It is intended to comply and should be interpreted in accordance with the following:

  • Family Law Act 1975 (Cth) and equivalent state legislation as in force from time to time
  • Insurance Council of Australia’s General Insurance Code of Practice: Guide to helping customers affected by family violence

Where indicators of family violence are identified by LKA Group, our client, or self-identified by the vulnerable person, this policy will apply to all interactions with the vulnerable person and no evidence will be required.

The LKA Group Vulnerabilities Support Officer (the Officer) is responsible for ensuring process in this Policy, and as set out in Industry Codes, regulations and by clients are followed. The Officer is also responsible for maintaining any secure records or reporting required by clients under this Policy.


All LKA Group operations are to be conducted in accordance with our Privacy and Confidentiality obligations and practices, as outlined in our Policies and provided for by clients, law, regulation and industry Codes of Practice.

Specifically when applying the Family Violence or Financial Hardship Policies, LKA Group team members must:

  • Not record any specific details of disclosures or indicators of family violence circumstances unless required by our clients. This Policy is to be applied consistently to all vulnerable persons and as such, records of their personal circumstances are not required.
  • Not disclose information (particularly physical addresses) between parties on any case, including between family members or joint policy holders. Steps should be taken, including the use of password protection if required, to secure this information on LKA documentation and systems to ensure no inadvertent disclosure occurs.
  • Not require evidence of family violence circumstances
  • Not share information with other team members except as necessary for the conduct of the case

Early recognition of family violence

LKA Group recognises that recognising family violence early in our interactions with vulnerable people can help reduce the impact of family violence. We understand that in our professional capacities, we are empowered to use the tools for recognising family violence to ensure we respect and protect the privacy and safety of vulnerable people with whom we interact.

Indicators that an adult person is affected by family violence include, but are not limited to:

  • The person discloses any past or present family violence, including any relevant legal proceedings or intervention orders
  • The person appears or sounds distressed or scared
  • The person appears to be taking instructions from a family member
  • The person remains silent while the family member does all the talking
  • The person does not know or does not understand that they have entered a contract for the relevant services, or that the services affect their rights and entitlements
  • The person asks questions about a family member’s behaviour or activities
  • The person has concerns about protection of their personal privacy, safety or security, including security of physical and other property
  • The person is reluctant to involve family members when changing the conditions of the relevant service, engaging the service or seeking Financial Hardship support
  • The person changes address or other contact details frequently, or does not want this information recorded
  • The person is consistently late to pay their obligations for the relevant service
  • The person offers unconvincing explanations for any injuries
  • The person requests copies of Family Violence or Financial Hardship policies
  • Clients advise LKA Group of the existence of family violence, or family violence indicators, in relation to the vulnerable person
  • LKA Group directly witnesses family violence affecting the vulnerable person

LKA Group recognises that family violence can affect young people differently, with indicators that include but are not limited to the above and:

  • The young person shows delinquent or offending behaviours
  • The young person uses controlling or violent behaviours
  • The young person is overly compliant and/or withdrawn
  • The young person is distrustful or violent towards adults

Any regulatory and social factors identify new indicators, these will be disseminated by LKA Group and will form part of this policy.

Activating this Policy

Immediately upon identification or notification of any of the above factors, or any other advice to activate this Policy,[1] LKA staff are to implement the following process:

Managing Vulnerable Customer Process

  1. Select the marker on our case management systems to flag that the Family Violence Policy applies to the case. This will notify all other team members to apply the policy without requiring any further disclosure by the vulnerable person or people. This should be done immediately upon identifying that the policy applies, or during the immediate next business day.
    Consult with the Officer to confirm the circumstances have been correctly identified and the best way to support the vulnerable person and their particular needs, including whether referral to any other service is appropriate.
  1. Within 24 hours of flagging the case, notify the following parties that this Policy applies:
  • Client instructing officer
  • Any designated client contact for relevant cases
  • Any contractors or consultants conducting the matter who would not be notified by the marker on the case
  • Any other vulnerable customer escalation points as advised by LKA Group and clients from time to time
  1. Conduct the case in accordance with LKA Group’s normal processes, best practice and our Core Values, and the policies and procedures outlined in this policy. This includes any obligations as to:
  • Minimising discussion about their personal circumstances to avoid re-victimising the vulnerable person, or ensuring these discussions are held in an appropriate manner with sufficiently experienced team members
  • Allocate team members to a case, taking circumstances and any expressed wishes of the vulnerable person into consideration
  • Make every reasonable effort to support any legal and procedural obligations on the vulnerable person which are relevant to the case
  • Observing the privacy and confidentiality obligations outlined in this policy
  • Maintaining internal case records, including as to activation and notification steps taken under this policy
  • Using a manner which is appropriate and sensitive, including culturally sensitive.
  • If required, seeking additional support or escalating the matter to personnel who have appropriate training and experience to conduct the matter in accordance with the policy.
  • Following processes or policies outlined by the client, including reporting on compliance with relevant processes

[1] This process also applies to and is consistent with activation of LKA Group’s Financial Hardship Policy, and to other processes for supporting vulnerable people.

Support for LKA Group team members

LKA Group offers support for team members affected by Family Violence in accordance with our core values, Policies and individual needs. Team members in need of support should advise their relevant manager or a preferred manager for confidential discussions of their circumstances and the supports that are available. This includes team members who are themselves affected or vulnerable people, and team members affected by disclosures made by others or their activities under this Policy. No LKA team member is required to put themselves at risk of harm in order to implement this policy.

LKA Group will keep copies of all client policies and procedures in relation to Family Violence and Financial Hardship on our internal servers and case management systems. These are to be accessed, reviewed and implemented wherever this Policy is activated.

LKA Group’s Family Violence and Domestic Hardship Policies are available on LKA Group’s website. Anyone requesting copies of these policies must be provided, within 2 business days, with appropriate direction to obtain them online, or provided with copies directly if online is not suitable. Vulnerable persons may be referred to the policies if appropriate to do so ; i.e. if their relevant circumstances are already under discussion and they are comfortable in the knowledge that LKA has identified these policies may apply.

LKA Group recognises that conducting cases under the Family Violence Policy can be confronting or challenging for staff. As such, LKA Group team members may request to have a case conducted by the designated Officer, or seek additional training, advice or support. These supports will be provided at a level appropriate to the team member’s role in the organisation and on the specific case. LKA Group’s Employee Assistance Program is also available.

LKA Group team members are not required to provide vulnerable people with support for family violence issues outside the scope of the case in question, and are discouraged from attempting to do so. If these discussions cannot be avoided, the case must be escalated, in an appropriate and sensitive manner, to the designated Officer. It may also be appropriate to refer the vulnerable person to the resources listed below in this Policy.

LKA Group will provide all team members with training on the purpose, obligations, processes and their conduct under this Policy. At minimum, team members will be provided with annual refresher training, particularly for new staff or where changes are introduced.

Resources and Referral Contacts


Translating and Interpreting Services (131 450)

1800 RESPECT (1800 737 732), the National Sexual Assault, Domestic Family Violence Counselling Service

Men’s Referral Service (1300 766 491)

MensLine Australia (1300 78 99 78)

National Disability Abuse and Neglect Hotline (1800 880 052)

Lifeline (13 11 14)

Kids Helpline (1800 55 1800)


Domestic Violence Crisis Service – (02) 6280 0900


Domestic Violence Line – 1800 656 463


DV Connect – 1800 811 811


Safe Steps Family Violence Response Centre – 1800 015 188

Domestic Violence Resource Centre Victoria


Women’s Domestic Violence Helpline – 1800 007 339 or (08) 9223 1188

Men’s Domestic Violence Helpline – 1800 000 599 or (08) 9223 1199


Domestic Violence Crisis Service Line – 1800 800 098


Family Violence Response and Referral Line – 1800 633 937

Family Violence Counselling and Support Service – 1800 608 122


Dawn House – (08) 8945 1388


Date: 27 May 2020